Governance and Administration of Other Postemployment Benefit Plans (2012) (CORBA)
Background. Entities that sponsor OPEB plans often administer the benefits. Alternatively, if a trust has been established to fund a plan, the trust’s governing body might be responsible for administering the plan.
Administration entails interpreting plan provisions, maintaining accurate and up-to-date demographic and other data, and making sure benefits are provided to retirees and their dependents. Additional responsibilities, depending on the administrative structure, can include periodic actuarial valuations, plan changes, actuarial valuations of proposed plan changes, and securing insurance providers. The scope of these responsibilities could increase if the plan sponsor has also established a trust to fund OPEB (see the GFOA best practice, Establishing and Administering an OPEB Trust).
Recommendation. The Government Finance Officers Association (GFOA) recommends that sponsoring entities provide a clear, well-documented governance structure to guide governing bodies and plan administrators, as a good governance structure establishes the framework for effective plan administration. To administer an OPEB plan, sponsoring entities, governing bodies, and plan administrators should:
1) Clearly delineate the governance responsibilities of fiduciaries and plan administrators in a comprehensive manual and the appropriate plan and trust documents.
2) Keep plan documents current and ensure that they reflect the substantive plan (see Governmental Accounting Standards Board Statement No. 45, Accounting and Financial Reporting by Employers for Postemployment Benefits Other Than Pensions). Administrative decisions and interpretations that accumulate over time should be formally documented and incorporated in any plan summaries and, when appropriate, in the plan document; doing so will help avoid legal issues regarding variations between the substantive plan and the official plan documents.
3) Provide participants with a summary plan description, a document that describes plan benefits and the plan’s significant features (see the GFOA best practice, Preparing an Effective Summary Plan Description for Retirement Systems). Conduct periodic educational sessions to review the summary plan description and answer participant questions (see the GFOA best practice, Communicating Health-Care Benefits to Employees and Retirees). Plan summaries and other documents can be construed as legally binding, so the plan sponsor, governing body, legal counsel, and administrative staff should review them carefully to avoid conferring rights and benefits that the plan sponsor did not intend and that are not included in the official plan documents.
4) Maintain all participant and beneficiary records necessary for administration of the plan, in accordance with state and local privacy laws:
| ||a) Participant and beneficiary names. |
| ||b) Demographic information on each participant and beneficiary. |
| ||c) Dates such as hire dates, for computing vesting, and birth dates, for determining Medicare eligibility. |
| ||d) Any other information needed for actuarial valuations or required by the plan document. |
5) Maintain any information necessary for legal and tax compliance (e.g., labor contracts, Internal Revenue Service determination letters).
6) Develop and maintain a comprehensive policy and procedures manual, and distribute updates on a timely basis. The manual should include:
| ||a) Current plan documents, Internal Revenue Service determinations, and administrative interpretations and decisions. |
| ||b) Policies, guidelines, and procedures regarding governance; administration; accounting, budgeting and financial reporting; and legal compliance and reporting. |
| ||c) Policies and procedures for the professional and technical training of fiduciaries and administrative management and staff, particularly in the areas of governance and fiduciary duties and responsibilities; plan compliance and legal issues; and best practices in OPEB plan administration and all relevant areas of responsibility. |
7) Hire an actuary to perform periodic valuations and to value the financial impact if any changes in the plan or to trust funding are proposed. The responsibility for appointing an actuary can rest with the plan sponsor, trust governing body, or the plan administrator.
8) Implement procedures to keep administrative costs as low as possible:
| ||a) Periodically review contractual services and purchases to make sure the product and services being purchased are priced optimally (see GFOA the best practice, Strategic Health-Care Plan Design). |
| ||b) Consider combining administrative activities with other departments or entities to lower administrative costs, and review this possibility periodically. |
Approved by the GFOA’s Executive Board, June 10, 2012